I am writing on behalf of the Friends of Ingrebourne Valley & Hornchurch Country Park (the Friends Group) to register the Friends Group’s opposition and comments in relation to the above application.

Since October 2012, the Friends Group has been in correspondence with both Havering Council and the applicant, Ingrebourne Valley Ltd, so that it could better understand the basis of the application and seek assurances regarding the impact of the proposals on Hornchurch Country Park for both its users and wildlife. Having reviewed the application, the Friends Group is of the opinion that assurances given by both Havering Council and the applicant have not been met. Furthermore, the Friends Group do not agree that the purported benefits to the Country Park set out in the application warrant the destruction of the existing meadow land and hedgerows at the proposed site, or the denial of the green and open space to the general public for a period of in excess of three years. Additionally, the Friends Group are not satisfied that the true environmental impact of the proposals has properly been addressed. Finally we can see no justification for the application to be granted in view of Havering Council’s own published Planning Policy documents the Local Development Framework and the Joint Waste Development Plan. Indeed, the application runs contrary to the Council’s own Havering Nature Conservation and Biodiversity Strategy.

At the forefront of the Friends Group’s concerns has been the environmental impact of the proposals. In a letter to the Friends Group on 16th October 2012, the then Leader of Havering Council, Michael White, stated that “A year long environmental study (4 seasons) is required before a planning permission can be submitted by Ingrebourne Valley Ltd.” In a further letter dated 28th November 2012, Council Leader Michael White again promised that “Ingrebourne Valley Ltd….will arrange for the year long environmental study to be completed”. During the course of a meeting with the applicant on 24th April 2013, the Friends Group were again assured that a year long environmental study looking at the impact upon the site itself, Ingrebourne Hill and the adjacent Ingrebourne Marshes Site of Special Scientific Interest (SSSI) would be undertaken. This was conveyed to our members in a newsletter, the wording of which was approved by Ingrebourne Valley Ltd.

However, the Phase 1 Ecology Survey submitted in support of the application is solely based upon a single day’s Field Visit undertaken in November 2012. No proper study of the site over a 12 month period, as had been consistently promised, was conducted. No attempt to assess the impact of the proposals on the key breeding and migration seasons has taken place. Instead, a single visit on a winter’s day has been the basis of the environmental considerations. As a result, the Ecology Report has failed to identify the importance of the proposed site and its surrounds to a number of protected and threatened species, in addition to the clear threat to more common species.

The Friends Group have written to the applicant and ECOSA, the company which completed the Ecology Report, to highlight the fact that bird and reptile species which are protected under Schedules 1 and 5 of the Wildlife and Countryside Act 1981 (Cettis Warblers and Adders) are believed to breed in the central ditch hedgerows and on the edge of the eastern border of the proposed site. Further, the Friends Group have advised ECOSA that Red Listed Birds of Conservation Concern species (Grasshopper Warblers and Skylarks) also breed on the proposed site. Photographic and anecdotal evidence of the above have been provided to ECOSA. The meadows also home Meadow Pipits and are important in the winter for waterfowl and waders such as Snipe and Jack Snipe when the meadows tend to be waterlogged. None of this is recognised in the report yet all of these species are impacted by the proposals.

The Ecology report is further undermined as it makes no reference to the impact of the proposed 200 lorry movements per day using the access haul road which runs adjacent to the Ingrebourne Marshes SSSI. Once again Schedule 1 protected and Red Listed species are directly affected. In particular, protected Marsh Harriers have attempted to breed in at least two of the last four years since the work, and the resultant disturbance this caused, on the existing Ingrebourne Hill ceased. This is a nationally scarce bird which had not been recorded as breeding in London for decades. Schedule 1 protected Bearded Tits and Cettis Warblers also breed here and it is a wintering home for Red Listed Bitterns.

ECOSA has advised that an additional report considering the haul road was conducted in August 2014. However, this has not been seen and does not form part of the application on the Havering Council website. It is worrying that ECOSA state in their letter to the Friends Group of 22nd August 2014 that “The access route is already in use by machines completing Ingrebourne Hill, therefore this would not be a new impact but does need assessing as a potentially larger impact in the updating report”. In fact, the access route has not been used in any significant way for a number of years and so the impact of these proposals with the resultant noise, dust and pollution implications on the SSSI will be significant. The above species have thrived since the disturbance of the original works ended. They would be put at risk if works were to recommence. The proposals have a potentially huge impact upon the SSSI which are not recognised in the Ecology Report, nor is it clear whether Natural England has been consulted

The application appears to be predicated upon purportedly providing increased links between Ingrebourne Hill and Hornchurch Country Park, whilst neglecting to mention that such links are readily provided by National Cycling Route 136 and glossing over existing pathways connecting the sites. The Friends Group members are far more concerned over the loss of access to the existing site and cycle routes than increasing links that are not required.

Equally, the application states that the final proposals will lead to a site of enhanced biodiversity to be enjoyed by the Park users. However, the Friends Group do not believe that to be the case. The existing meadow land provides a welcome, unique and necessary open space. There is no need for a further hill, or indeed for further woodland. These habitats already exist on the established Ingrebourne Hill and the experience from the last project shows that trees have not taken on the eastern side of the hill. The applicants themselves have anticipated that only the non native Italian Alder will be able to establish itself.

If the applicant really wishes to create a strong link between Ingrebourne Hill and Hornchurch Country Park, then a simple style/foot bridge across the ditch at the southern edge of the site would suffice. Many local Parks such as Bedfords Park and South Weald consist of hills with steep slopes and are extremely popular with their users. There is no need to landscape the existing hill further or create another unnatural hill in what is after all a floodplain. Enhanced biodiversity and a better environment for the public could be obtained by the applicant opening the eastern side of the existing Ingrebourne Hill to the public and creating pathways through a properly soiled and planted wildflower meadow.

The proposed site is not one of the Site Specific Allocations identified in Havering’s Local Development Framework or The Joint Waste Development Plan, to which Havering Council is a party. It appears from the Joint Waste development Plan that it is Havering’s target to recycle and reuse 95% of construction, excavation and demolition waste by 2020. Given that the source of the inert material outlined in the proposals is likely to come from this sector, then shouldn’t the onus be on recycling the material on site or at the existing centres identified within the policy document rather than creating a new landfill? If the material proposed to be used in the landfill has already undergone this process, then shouldn’t it be continued to be moved outside of London as recognised in the Joint Waste Development Plan and put to use where required?

The Friends Group have restricted their comments to the potential impact upon the Ingrebourne Valley & Hornchurch Country Park. However, it would be remiss not to mention the other concerns raised by members relating to traffic congestion, noise and pollution. No doubt these concerns will feature heavily in representations made by others.

Finally, it should be noted that the Friends Group are not simply adverse to change, as is shown by their support of the development of the Essex Wildlife Trust Visitor Centre. However, such change must bring benefit to the Country Park for its users and wildlife. These proposals do not do that and we would ask that they should be rejected if Havering Councils own Nature Conservation and Biodiversity Strategy is to retain any credibility.

If you wish to see full copies of the correspondence from which quotes have been used above for context, please do not hesitate to contact me.

After the General Meeting on Monday 15th September 2014, where people who attended or voted by email, voted whether to oppose, support or have no representation for the Ingrebourne Hill Landfill Extension. The vote was counted, the results are:-

To oppose landfill - 16 votes

To support landfill - 1 vote

No representation - 1 vote

Therefore, the Friends Group will be opposing the Landfill Extension to Ingrebourne Hill. Please see the letter below that has been sent to the Council.